The Buyer's Right to Avoid the Contract: Comparison between Provisions of the Cisg and the Counterpart Provisions of the Pecl
University of Haifa - Faculty of Law; NYU School of Law - Straus Institute for the Advanced Study of Law and Justice; Yale Law School
AN INTERNATIONAL APPROACH TO THE INTERPRETATION OF THE UNITED NATIONS CONVENTION ON CONTRACTS FOR THE SALE OF GOODS John Felemegas, ed., Cambridge University Press, 2007
This article presents and analyzes the law pertaining to the Buyer's power to avoid (terminate) an international sales contract for breach of contract by the buyer. The analysis studies two major contractual regimes: the UN convention on Contracts for the International Sales of Goods, 1980 (CISG) and the European Principles of Contract Law, 2003 (PECL), with some comparisons to the UNIDROIT Principles, the UCC and the BGB, and judicial opinions from several legal systems applying the CISG and other relevant law.
Number of Pages in PDF File: 21
Keywords: Buyer, contract, Avoidance, CISG, PECL, Termination, Self-Help
JEL Classification: J41, K12, K10, K33, K49, K11, L14, M55, K00Accepted Paper Series
Date posted: June 6, 2006
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